By Rene Umberger
This article was originally featured in the Sierra Club Newsletter of September 2009

Increasingly snorkelers and divers in Hawaii are asking “Where have all the fish gone?” Reef fish decline can be attributed to several factors, however none weigh so heavily as the losses due to extraction, including collecting reef animals for the home tanks of hobby aquarists.

According to the U.S. Coral Reef Task Force, “Severe overfishing for the aquarium trade occurs even in the United States. Aquarium fish species have declined by 59% over the last 20 years in Hawaii…Aquarium fishes outside of reserves experience significant declines – from 14% to 97%.”

The fish collected are Hawaii’s most beautiful, unusual and often rarest species. Given that the “marine ornamental” trade operates with few species limits and no limits on the number of fish they may collect, nor on the numbers of permits issued, it’s no wonder reef fish populations are in serious decline.

Hawaii has the highest rate of endemism for warm-water fishes, worldwide. These rare and beautiful species are highly prized by aquarium hobbyists and in fact, 45 percent of Hawaii’s top 20 collected species are endemic. As such, there is no replacement pool to draw from if they are over collected to the point where they cannot rebound, so these unique species could be lost forever. Each example of the sacrifice and waste associated with the aquarium industry diminishes our reefs and ultimately begs moral questions. In 2007, Hawaii’s collectors reported that of the 700,000-plus animals collected, 20,340 animals died before being sold (the true numbers are estimated to be several times higher). Putting 20,340 fish in perspective, it equates roughly to every fish on a reef the size of five football fields.

Half of Hawaii’s 20 most collected species are listed by aquarium experts as “unsuitable for captivity.” The most egregious examples of fish sacrificed for brief entertainment in a tank are the coral-eating butterflyfish, the Moorish Idol and the Hawaiian cleaner

wrasse; all known to starve within weeks because their preferred foods are not available in captivity. Additionally, collecting cleaner wrasses is especially harmful to the reefs; their removal reduces overall fish diversity and abundance quickly in the areas they’re taken from.

Mortalities continue throughout their journey from wholesalers to retailers and finally to hobbyists. Many will die shortly after arriving on the mainland from the stress of being starved, drugged and bagged for shipping, and the rest will succumb because they are almost impossible to keep outside their native reef habitat. Bob Fenner, a well-respected, 40-year veteran of the aquarium industry, wrote, “It is my estimate that even given sustainable collection practices . . . less than one percent live more than a year in captivity.”

Four-fifths of all collected species are herbivores, affecting the reef’s algae/coral balance, and most are Yellow tangs. Recent research in Hawaii shows that Yellow tangs are long-lived, surviving on reefs for decades; the oldest found so far is 41. Collected in Hawaii by the hundreds of thousands annually, suppliers consider them easy to care for and good for beginners, but only a few thousand of them will live beyond a year. The aquarium trade claims the losses are worth it: hobbyists cite their tanks’ “educational value” and industry professionals cite the need for livestock to support their lucrative “dry goods” sales of tanks, filters and lights. Common sense says reef animals are fueling a disposable hobby: When the fish die, they are thrown out and replaced, like cut flowers.

If you believe Hawaii’s reefs can no longer support the luxury trade in reef animals for a hobby, then visit our web site to sign the petition and learn more: www.FortheFishes.org. For questions or to join our “Take Action” mailing list, contact Rene directly at octopus@maui.net. Rene is a scuba instructor, underwater tour guide, member of the Maui Nui Marine Resource Council and is a member of the Sierra Club.

Letter Opposing Open Ocean Aquaculture Signed by 10 Scientists

August 3, 2009
Secretary Gary Locke
U. S. Department of Commerce
14th Street and Constitution Ave. N. W.
Washington, DC 20230

Delivered via e-mail to Jess Beck, Southeast Regional Office, NMFS at Jess.Beck@noaa.gov; and posted electronically to the Federal eRulemaking Portal at http://www.regulations.gov

Re: Proposed Rule 0648-AS65: Fishery Management Plan for Regulating Offshore Marine Aquaculture in the Gulf of Mexico

Dear Secretary Locke:

Thank you for the opportunity to provide a scientific perspective on the environmental risks of open ocean aquaculture to help inform the Department of Commerce’s pending decision to approve or reject the Gulf of Mexico Aquaculture Fisheries Management Plan (FMP). We are a diverse group of academic scientists with experience in marine ecology, aquaculture, and fisheries who have published extensively in the peer-reviewed scientific literature. We identify a range of environmental risks of marine aquaculture, many of which should be addressed at an ecosystem scale to ensure that aquaculture ameliorates, rather than exacerbates, pressure on the oceans. We conclude that a coordinated, ecosystem-based regulatory approach, operating at the national level, is necessary to achieve a sustainable future for open ocean aquaculture in the United States. Without this approach, the piecemeal development of a marine aquaculture industry could result in significant and potentially irreversible environmental consequences. For this reason, we recommend that the Gulf of Mexico Aquaculture FMP should be disapproved.

There are six environmental risks of open ocean aquaculture that are most relevant to decisions about how the United States might proceed with this relatively new method of farming seafood. They are:

  1. Use of marine resources, 
  2. Risks of escaped fish to wild fish and associated ecosystems, 
  3. Nutrient, chemical, and habitat impacts, 
  4. Risk of disease and parasite amplification and retransmission, 
  5. Impacts of drug and chemical use, and 
  6. Impacts on predators and other wildlife. 

Use of Marine Resources
Aquafeed for many of the “carnivorous” species likely to be farmed in open ocean environments (e.g. cod, halibut, seabass, striped bass, yellowtail, and yellowfin tuna) contains very high percentages of fishmeal and fish oil (Tacon and Metian 2008). Average estimates of the ratio of wild fish required to produce farmed fish are 2.2 for “marine fish” and ~5.0 for salmon (Tacon and Metian 2008, Naylor et al. 2009). The wild forage fishes caught for aquafeeds play important ecosystem roles as food sources for higher trophic-level marine predators (Cury et al. 2000, Worm et al. 2006, Alder et al. 2008). As aquaculture has grown dramatically over the past two decades, the total demand for fishmeal and fish oil for use in aquaculture feeds has similarly expanded while the supply has remained relatively constant, thus increasing aquaculture’s share of global fishmeal and fish oil use (Tacon et al. 2006, Tacon and Metian 2008, FAO 2009, Naylor et al. 2009). Additional global growth in industrial fish production has the potential to undermine marine food webs by redirecting food sources away from those wild species most dependent on them (Pauly et al. 2002, Pauly et al. 2005, Karpouzi et al. 2007).

These facts all point to the use of marine resources as a key constraint in a sustainable future for aquaculture. Severing the reliance of fish farming on wild fish requires efficiency improvements at the farm level as well as a regulatory structure that sets overarching sustainability requirements for the industry as a whole, as most of the forage fish used for aquaculture are caught outside of U.S. waters (FAO 2009). Minimizing the use of forage fish in feeds and creating incentives for substitutes for wild-caught fishmeal and fish oil (including seafood processing byproducts, terrestrial plants, animal byproducts, single cell proteins and oils, and marine and terrestrial invertebrates) are needed if these feed sources are to be widely adopted by the aquaculture industry (Naylor et al. 2009).

Risks of Escaped Fish to Wild Fish and Associated Ecosystems
Aquaculture is known to be a major vector for exotic species introduction (Carlton 1992, Carlton 2001), causing concern over the ecological impacts that escaped farmed species can have on wild fish and the environment, whether the farmed species are native or exotic to the area in which they are farmed (Volpe et al. 2000, Naylor et al. 2001, Youngson et al. 2001, Myrick 2002, Weber 2003). Farmed salmon are known to regularly escape from net pen systems, negatively impacting wild salmon stocks by increasing competition for food and breeding sites, as well as reducing the fitness of wild fish through interbreeding (Einum and Fleming 1997, Youngson and Verspoor 1998, Volpe and Anholt 1999, Fleming et al. 2000, Volpe et al. 2000, Jacobsen and Hansen 2001, Volpe et al. 2001, McGinnity et al. 2003, Naylor et al. 2005, Hindar et al. 2006). As compared to salmon aquaculture facilities, which are generally sited in sheltered bays, net-pen systems in open ocean environments face increased risk of failure due to increased exposure to storms and stronger currents.

Developing separate broodstock to allow for selection of desirable growth characteristics is a hallmark of traditional agriculture and livestock production. To date, this has been common practice in aquaculture as well. However, allowing these practices to continue for aquaculture in open ocean environments, where fish will inevitably escape, greatly increases the risk to natural ecosystems of genetically-distinct farmed fish, even if these fish are native to the farming area. If the U.S. is to prevent environmental damage related to fish escapes, explicit regulations for broodstock maintenance and fish escape standards are needed that account for both individual farm-level effects and the cumulative impact of escapes occurring across a large number of farms. In the absence of these regulatory safeguards, permitting open ocean aquaculture in the Gulf of Mexico at this time risks significant harm to the environment and should not be allowed.

Nutrient and Habitat Impacts
Wastes, both dissolved and particulate, from open net pen systems are released untreated directly into nearby bodies of water and can have large impacts on the surrounding environment (Gowen et al. 1990, Beveridge 1996, Costa-Pierce 1996). More than half of the total nitrogen and phosphorus fed to fish in commercial farms is released into the surrounding environment (Beveridge 1996, Fernandez-Jover et al. 2007). In Japan, intensive culturing of finfish and its consequent generation of organic wastes has adversely affected the surrounding environment via deoxygenation (Hirata et al. 1994), outgassing of hydrogen sulfide (Tsutsumi 1991), and blooms of harmful plankton (Yokoyama 2003, Nakamura et al. 1998).

While proponents of offshore aquaculture frequently cite deep water and high flushing rates as reasons for low concern over nutrient pollution in these habitats, emerging science suggests this may be unjustified. A detailed study of a commercial-scale open ocean aquaculture facility in Hawaii found striking changes in benthic species diversity and community structure under and nearby submerged sea cages despite relatively deep water and high current velocity (Lee et al. 2006). High-resolution models of waste transport from aquaculture pens indicate that dissolved nutrients (from excess feed as well as fish excretion) do not disperse as rapidly and as uniformly as was previously assumed (Venayagamoorthy et al. 2009). This evidence suggests that the adage of “dilution is the solution” is not the appropriate framework under which to expand open ocean aquaculture in the U.S., especially in areas such as the Gulf of Mexico which are already under severe nutrient stress. To adequately address the cumulative impacts of nutrient input from multiple aquaculture facilities, aquaculture must be regulated and managed at the ecosystem level, not by relying solely on local-scale, individual permitting decisions such as those allowed by the Gulf of Mexico aquaculture FMP.

Risk of Disease and Parasite Amplification and Retransmission from Farmed Fish to Wild Fish
It is well known that intensive fish culture, particularly of non-native species, has been involved in the introduction and/or amplification of pathogens and disease in wild fish populations (Hastein and Linstad 1991, Nese and Enger 1993, Kent 1994, Nylund et al. 1994, Bakke and Harris 1998, Blazer and LaPatra 2002). In recent years, the issue of amplification and retransmission has received much attention because of the dramatic consequences of the spread of parasitic sea lice from salmon farms to wild salmon (Tully and Whelan 1993; Costelloe et al. 1996; Grimnes and Jakobsen 1996; Gargan 2000; Bjorn et al. 2001; Heuch and Mo 2001; Bjorn and Finstad 2002; Butler 2002; Morton et al. 2004; McKibben and Hay 2004; Penston et al. 2004; Krkosek et al. 2005, 2006, 2007; Morton et al. 2005). Disease outbreaks in other fish grown in open net pens appear to be common as well. For example, yellowtail farmed in the Mediterranean, Japan, and New Zealand have suffered substantial mortalities from monogenean parasites (Whittington et al. 2001; Hutson et al. 2007).

Of the six major environmental risks of open ocean aquaculture, disease is the one for which ecosystem-level management is most critical. Disease at the farm level is a husbandry issue, but it is the transfer of diseases from farm to farm and back to the wild that poses the largest environmental risks. Chile’s experience with Infectious Salmon Anemia in farmed salmon (Mardones et al. 2009, Vike et al. 2009) is a cautionary tale. Farm-level management led to numerous salmon farms being sited too closely together. Only after the salmon industry was decimated by the spread of this disease did Chilean authorities take the first steps toward breaking the disease cycle by developing “neighborhoods” to limit both farm-level and regional fish production (Intrafish 2009). If the U.S. is to prevent these types of disease dynamics, it must develop an ecosystem-based approach to aquaculture management that plans for expansion within an explicitly spatial context. As such an approach does not currently exist, approving the Gulf of Mexico aquaculture FMP risks significant harm not only to the environment, but to the aquaculture industry itself.

Impacts of Drug and Chemical Use
Most aquaculture operations use a variety of chemicals, including antifoulants, pesticides, and antibiotics (Tacon and Forster 2000), which can have negative effects on marine ecosystems or human health. Copper-containing paints, commonly-used antifoulants in the aquaculture industry, are toxic to many marine organisms, including seaweeds, mollusks, and Atlantic cod embryos (Andersson and Kautsky 1996, Granmo et al. 2002, Braithwaite and McEvoy 2004). Use of antibiotics has been shown to result in bacterial resistance in some aquaculture environments and to influence antibiotic resistance in humans (Kerry et al. 1996, Sapkota et al. 2008). Pesticides whose residues are known to be harmful to other marine life (Abgrall et al. 2000, Grant 2002) are sometimes used to control sea lice levels on farmed salmon (Roth 2000). In order to minimize the deleterious effects these chemicals have on the marine environment, their responsible use in aquaculture must be regulated by national agencies under a coordinated plan.

Impacts on Predator Populations
Expansion of open ocean aquaculture in the U.S. may also pose environmental risks to predators and other wildlife. In coastal salmon farming, a range of techniques, including the use of predator nets and underwater acoustic deterrent devices, are commonly used to reduce the impact of predators on stocks of farmed fish. These techniques, while generally successful at reducing losses of farmed fish, can have dramatic unintended consequences for the predators themselves, including alteration of natural behavior and the entanglement and subsequent drowning of large numbers of these air-breathing mammals (Morton and Symonds 2002, Wursig and Gailey 2002, CBC News 2007).

In open ocean environments, little is known about the potential impacts of fish farms on predators and other wildlife, but experience with farmed salmon suggests this will be an important concern. Limited evidence suggests that sharks and other large pelagic predators are attracted to submerged net pens (Galaz and de Maddalena 2004, NOAA 2005) and that predators that have become habituated to the presence of net pens, and hence a threat to human safety, have been killed (Lucas 2006). Should this practice become commonplace as the U.S. industry expands, this could put already vulnerable shark populations (Stevens et al. 2000, Baum et al. 2003, Myers and Worm 2005, Camhi et al. 2009) at further risk. Finally, submerged net pens and their associated mooring lines could pose entanglement risks to whales and other cetaceans, whose migration routes or foraging behavior bring them in close proximity to fish farms (Upton et al. 2007). Mitigating the effects of a young and growing aquaculture industry on predators and wildlife will require additional research on the interaction of farms and marine wildlife as well as the population consequences of the cumulative impact of those interactions.

A Final Note on Cumulative Impacts of Multiple Aquaculture Facilities

When the impacts of a single aquaculture operation are considered in isolation, they may be considered to be relatively mild. However, as the aquaculture industry grows, and should facilities be sited in close proximity to one another for economies of scale, the effects of their combined impacts may be greater than the sum of their individual impacts. This can be the case with nutrients, as well as with disease transfer, impacts of escapes, use of marine resources, and impacts on predators. To avoid these cumulative impacts and help avoid or ameliorate many of the risks discussed above, the precautionary approach should be a central tenet of the planning, management and permitting of aquaculture facilities.

Due to the scientifically documented, serious risks of offshore marine aquaculture outlined in this letter, we conclude it is critical for the U.S. to develop a consistent, precautionary set of environmental standards and implement regulations designed to protect the nation’s federal marine waters. In their absence, the development of a marine aquaculture industry in a piecemeal fashion, such as through approval of the Gulf of Mexico aquaculture FMP, could result in significant and potentially irreversible environmental consequences, including water pollution from waste products and chemicals, threats of disease transmission to wild fish populations, harmful effects on native marine species from escaped farmed fish, and ecosystem impacts of the increasing use of wild forage fish for aquaculture feeds.

Thank you for the opportunity to provide this scientific analysis on the ecological risks of marine finfish farming to help inform your decisions on how the U.S. should address this important issue. We conclude that an ecosystem approach to aquaculture management is critical to the long-term future of a sustainable domestic offshore aquaculture industry and incompatible with approval of the Gulf of Mexico aquaculture FMP at this time.


Rosamond L. Naylor, Ph.D.
Professor, Environmental Earth System Science
Stanford University

Felicia C. Coleman, Ph.D.
Florida State University Coastal & Marine Laboratory

Ian A. Fleming, Ph.D.
Professor, Ocean Sciences Centre
Memorial University of Newfoundland

L. Neil Frazer, Ph.D.
Professor, School of Ocean and Earth Science and Technology
University of Hawaii at Manoa

Les Kaufman, Ph.D.
Professor, Biology
Boston University Marine Program

Jeffrey R. Koseff, Ph.D
Professor, Civil and Environmental Engineering
Stanford University

John Ogden, Ph.D.
Director, Florida Institute of Oceanography
University of South Florida

Laura Petes, Ph.D.
Postdoctoral Associate
Florida State University Coastal & Marine Laboratory

Amy R. Sapkota, Ph.D., MPH
Assistant Professor, Maryland Institute for Applied Environmental Health
University of Maryland College Park, School of Public Health

Les Watling, Ph.D.
Professor, Department of Zoology
University of Hawaii at Manoa



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Sapkota, A., Sapkota, A. R., Kucharski, M., Burke, J., McKenzie, S., Walker, P., et al. (2008). Aquaculture practices and potential human health risks: current knowledge and future priorities. Environment International, 34:1215-1226.

Stevens, J. D., Bonfil, R., Dulvy, N. K., & Walker, P. A. (2000). The effects of fishing on sharks, rays, and chimaeras, and the implications of marine ecosystems. ICES Journal of Marince Science , 57:476-494.

Tacon, A. G., & Forster, I. P. (2000). Global trends and challenges to aquaculture and aquafeed development in the new millennium. In International Aquafeed – Directory and Buyers’ Guide 2001 (pp. 4-25). Uxbridge, UK: Turret RAI.

Tacon, A. G., & Metian, M. (2008). Global overview on the use of fish meal and fish oil in industrially compounded aquafeeds: Trends and future prospects. Aquaculture , 285:146-158.

Tacon, A. G., Hasan, M. R., & Subasinghe, R. P. (2006). Use of fishery resources as feed inputs to aquaculture development: trends and policy implications. Rome, Italy: FAO.

Tsutsumi, H., Kikuchi, T., Tanaka, M., Higashi, T., Imasaka, K., & Miyazaki, M. (1991). Benthic faunal succession in a cove organically polluted by fish farming. Marine Pollution Bulletin , 23:233-28.

Tully, O., & Whelan, K. F. (1993). Production of nauplii of L. salmonis from farmed and wild salmon and its relation to the infestation of wild sea trout off the west coast of Ireland in 1991. Fisheries Research , 17:187-200.

Upton, H. F., Buck, E. H., & Borgatti, R. (2007). Open Ocean Aquaculture CRS Report for Congress.Congressional Research Service, Order Code RL32694.

Venayagamoorthy, S. K., Fringer, O. B., Koseff, J. R., Chiu, A., & Naylor, R. L. (2008). Numerical modeling of aquaculture dissolved waste transport in a coastal embayment. Submitted.

Vike, S., Nylund, S., & Nylund, A. (2009). ISA virus in Chile: evidence of vertical transmission. Archives of Virology , 154:1-8.

Volpe, J. P., & Anholt, B. R. (2001). Atlantic salmon in British Columbia. Marine Bioinvasions: Proceedings of the First National Conference (January 24-27, 1999) (pp. 256-259). Cambridge, MA: Massachusetts Institute of Technology.

Volpe, J. P., Anholt, B. R., & Glickman, B. W. (2001). Competition among juvenile Atlantic salmon and steelhead: relevance to invasion potential in British Columbia. Canadian Journal of Fisheries and Aquatic Sciences , 58:197-207.

Volpe, J. P., Taylor, E. B., Rimmer, D. W., & Glickman, B. W. (2000). Evidence of natural reproduction of aquaculture-escaped Atlantic salmon in a coastal British Columbia river. Conservation Biology , 14:899-903.

Weber, M. L. (2003). What price farmed fish: a review of the environmental and social costs of farming carnivorous fish. Providence, RI: SeaWeb Aquaculture Clearinghouse.

Whittington, I. D., Corneillie, S., Talbot, C., Morgan, J. A., & Adlard, R. D. (2001). Infections of Seriola quinqueradiata and S. dumerii in Japan by Benedenia seriolae (Monogenea) confirmed by morphology and 28S ribosomal DNA analysis. Journal of Fish Diseases , 24:421-425.

Worm, B., Barbier, E. B., Beaumont, N., Duffy, J. E., Folke, C., Halpern, B. S., et al. (2006). Impacts of biodiversity loss on ocean ecosystem services. Science , 314:787-790.

Wursig, B., & Gailey, G. A. (2002). Marine mammals and aquaculture: conflicts and potential resolutions. In R. R. Stickney, & J. P. McVay, Responsible Marine Aquaculture (pp. 45-59). New York: CAP International Press.

Yokoyama, H. (2003). Environmental quality criteria for fish farms in Japan. Aquaculture , 226:45-56.

Youngson, A. F., & Verspoor, E. (1998). Interactions between wild and introduced Atlantic salmon. Canadian Journal of Fisheries Aquatic Science , 55:153-160.

Youngson, A., Dosdat, A., Saroglia, M., & Jordan, W. C. (2001). Genetic interactions between marine finfish species in European aquaculture and wild conspecifics. Journal of Applied Ichthyology , 17:155-162.

Hutson, K., Ernst, I., Mooney, A. J., & Whittington, I. D. (2007). Risk assessment for metazoan parasites of yellow tail kingfish Seriola lalandi in South Australian sea-cage aquaculture. Aquaculture , 271:85-99.

Costelloe, M., Costelloe, J., & Roche, N. (1996). Planktonic dispersion of larval salmon lice, L. salmonis, associated with cultured salmon, S. salar, in western Ireland. Journal of the Marine Biological Association of the United Kingdom , 76:141-149.

Honokowai Restoration Project

The& Honokowai Cultural Overlay stabilization project is a component of Ka`anapali 2020, which includes restoration and preservation of an ancient farming archeological site, as well as a Multi-Cultural Center. The project is supported by businesses, organizations and the people of Maui. Steady progress is being made at the work site.


In October 2002, the Hawaii State Archaeological Society, with more than 20 archaeologists, inspected the project. They all felt Honokowai sites were among the best projects currently in the state. Many of them wanted to work with the Overlay team. They pointed out possible burials, house sites, trails, auwai, heiaus, shelters, and were interested in the land court award names.


The Multi-Cultural Committee extends its appreciation for the help received from Alexander & Baldwin to purchase tools; Ken Ota of Irrigation Systems, Inc. for 1600 feet of two-inch polyethylene waterlines; Jan Dapitan of Community Work Day for irrigation lines, valves, transportation; 14 Americorps workers for five days; and James Carpio of Jay’s Nursery for flat bed truck transportation and agricultural supplies.


The community is encouraged to participate in this special place. Families, children and elders are always welcome. Bring lunch, water, gloves, hand tools, hats and repellent.


Honokowai Archaeological Cleanup Project volunteers welcome every Saturday. Meet at 9am at the “Sugar Cane Train” parking lot off Honoapiilani Hwy, turn mauka at Pu’ukoli’i St. (north of Ka’anapali).Clean Archaeological sites an12/18/05dsey at 572-8085.



The Hawai`i Superferry presents a classic case of how not to do business in Hawai`i. Superferry’s lack of planning and violation of the Hawaii Environmental Protection Act has created a public debacle, inconvenienced their customers, and put Hawaii’s environment at risk. Three years ago the Sierra Club, Maui Tomorrow, and Kahului Harbor Coalition asked the Hawai`i Superferry and the Lingle Administration to complete an environmental review of the Superferry. Unknown environmental risks, concerned neighbor island communities, and a clear reading of the law demanded it. The review would have occurred while other planning proceeded. The Administration and Superferry corporation, however, decided to gamble and chose to skip this mandatory environmental disclosure process.

A unanimous Supreme Court decision – announced just hours after oral argument– called their bluff. Then, despite the decision from Hawaii’s highest court, Superferry decided to roll the dice again and start service early. Again, they lost when a judge ordered them to cease service to Maui.

A responsible company doesn’t allow a problem to get to the point where they receive a restraining order. They lost in court, lost neighbor island support, and lost credibility.

Poor planning and lack of community involvement angered some Kaua`i residents to the point of taking justice into their own hands, risking arrest (or their lives) to block the arrival of the Superferry. The Sierra Club does not condone lawbreaking – neither by the Superferry nor by the protesters. The protests, however, surely reflect the deep sense of injustice many neighbor islanders feel toward the Superferry – contempt that has been irresponsibly inflamed by proceeding in open disregard of the law.

This is why the public review process is so important in the first place: to understand the environmental tradeoffs, to involve the affected communities, to separate fact from fiction, and to protect the environment against unintended consequences. Unintended conssequences like the spread of mongoose to Kaua`i. Or the disastrous varroa bee mite to Maui. Or coqui frogs everywhere. These pests can easily become stowaways underneath car or truck bodies or inside the bushels of produce being transported. And with the Superferry shuttling hundreds of private vehicles and farm trucks daily, spreading these pests is all but guaranteed – unless proper protections are put in place and funded. For neighbor island farmers, the cost of new invasive species brought by the Superferry could be their livelihood.

The high-speed vessel operation itself may pose a threat to the marine mammals. Traveling at 35 knots through known whale calving areas may make riders sick in more ways than one. Environmental reviews are used to fix problems before they occur. They don’t just look at wildlife but at social consequences such as unbearable traffic, curtailment of traditional Hawaiian activities, and costly freight increases to small businesses. What are the best ways to minimize harm to Hawaii’s unique environment and communities? That’s what we’ll learn with an environmental review. Ultimately, the review process produces a better outcome for all involved, island-style.

When public taxpayer dollars are used as they are with the Superferry, the public has a right to ask questions – and get answers. Otherwise we might all be taken for a ride.

The environmental review process is a routine procedure. Private companies and State and Federal agencies complete reviews all the time. The Department of Transportation (DOT) has completed numerous such reviews in the past year. New roads, harbor improvements, airport upgrades: they all go through the process. Significantly, the DOT even required and conducted a full environmental impact statement when a ferry system just on the Island of O`ahu was proposed.

Three decades ago when the Hawai`i Environmental Protection Act was enacted, State elected leaders made clear that the environmental review be a “condition precedent” to implementation of the proposed action. In other words, the study must be complete before the project starts. We must look before we leap. It’s not only common sense, it’s the law.

Yes, the review process can be messy because you have to deal with real science – not soundbites and promises – and real public input. Superferry would actually have to respond to questions in writing and publish the answers. Yes, it takes a few months to complete. But the resulting document provides clear answers on what the adverse impacts are expected – and how best to prepare for them.

So why did the Superferry and the Administration chose to skip this process three years ago? Why did they chose not to complete an environmental review after the community groups asked, after neighbor island lawmakers asked, after the Maui, Kaua`i, and Big Island county councils asked, even after the State’s own Environmental Council ruled that it was required. Why not? Were they worried about disclosing something the public wouldn’t like to hear?

Hawai`i is like no other place on Earth, with hundreds of species found nowhere else on the planet and deep community values. To protect this uniqueness, the Sierra Club, Maui Tomorrow and Kahului Harbor Coalition requested Superferry and the DOT to comply with our keystone environmental law years ago. They chose to ignore the law. Our position hasn’t changed: if the Superferry is going to operate in Hawaii’s waters, it must to be done right. The first step is to comply with our state laws.

Superferry Facts and Myths

Refuting the Myths:  Hawaii  Superferry
by Ron Sturtz, President of Maui Tomorrow Foundation, Inc

Many people have asked that I provide a factual overview of the potential environmental impacts of the Hawaii Superferry, and the status of current legal challenges.  I hope that the following facts – in response to a few well-intentioned and passionate, but misinformed letters, editorials and news reports – will be helpful to the discussion.

Myth:  The State and Federal Courts have ruled that an Environmental Impact Statement (EIS) is not necessary:

 Fact: To quote Attorney General Mark Bennett in a published interview on February 6 by KGMB-9 TV:  “No court has ruled against the argument that an EIS was required in this case.”

Myth: All legal challenges are behind the Superferry.

 Facts: The Maui Circuit Court has granted legal standing to Maui Tomorrow Foundation, Inc., the County of Maui, and the Kahului Harbor Coalition to seek an EIS encompassing the entire Kahului Harbor and all its users, including the Hawaii Superferry. This case is ongoing and the parties are in negotiation. An earlier case which challenged the exemption from an EIS, given to the Hawaii Superferry by the Department of Transportation, has been appealed to The Hawaii Supreme Court. This action followed an initial ruling that Maui Tomorrow did not have legal standing in the case, and that the exemption could stand. That case is still open and an EIS may still be required.

Myth:  That this is an “11th Hour” claim by environmentalists seeking to stop the Superferry.

Facts: The public requested an EIS as early as the PUC hearing of November 19, 2004. Efforts to mediate disagreements over legal requirements of addressing environmental impacts led to litigation on March 21, 2005. There has been plenty of time – well over two years – for the Superferry to conduct an EIS.

The goal of an EIS is to study and address the potentially harmful economic, social and environmental impacts of the Superferry, and not to run it aground. The Maui, Hawaii, and Kauai County Councils all passed resolutions last year to require an EIS. The Maui County Council also directed County Attorneys to join in the current lawsuit against the State. Testifiers and sign-holding protesters on Maui have included a broad coalition of harbor workers, farmers, canoe paddlers, construction workers, residents from all parts of the island, as well as state and local governmental representatives.

Myth: The Hawaii Superferry is no more dangerous to whales than other vessels and ferries that regularly travel in oceans around the world, including Alaska, where humpback whales spend their summers. The Superferry’s Whale Avoidance Policy will adequately address potential collisions.

 Facts: Hawaii has never seen a vessel like this twin hull, 350 foot craft, traveling at speeds up to 40 knots. Just last month, a cruise ship in Alaska was fined $750,000 for killing a pregnant humpback whale, while traveling at a speed estimated at only 17-20 knots. The much-touted Whale Avoidance Policy (WAP) promised use of “forward looking sonar”, however it wasn’t ever installed in the vessel, and isn’t deemed practical. Their reduced speed of 25 knots is almost double the NOAA recommended safe speed of 13 knots. Furthermore, the Sanctuary Advisory Council, which adopted the WAP, is chaired by Terry O Halloran, HSF’s hired spokesperson. This represents a clear conflict of interest.

Myth:  Law enforcement and agricultural inspections will be stringent, and will stop the spread of drugs and invasive species.

Facts:  The time allotted for vehicle inspection will be insufficient to conduct adequate security and agricultural screening, due to the sheer numbers of vehicles loading and off-loading the giant ferry. 250 cars loading in 15 minutes leaves 3.6 seconds to thoroughly inspect each vehicle. With even 6 inspectors, that leaves 21.6 seconds per car.

Myth: The Hawaii Superferry is being unfairly singled out when nobody else has been required to due an EIS .

Facts: The last time a ferry was proposed, an EIS was required by the State. In 1988, the Oahu Intra-island Ferry System proposed to set sail. It, too, proposed the use of State lands and State funds. On January 19, 1989, the State DOT director Edward Y. Hirata prepared a 561 page Final Environmental Impact Statement that was directed to the Governor’s office for consideration. And that EIS didn’t even have to deal with inter-island issues of invasive species and sailing through whale-laden waters. That Ferry proposal had far fewer environmental challenges facing it, and yet, the DOT saw fit to prepare an EIS for the State Governor.

Myth: The State will incur millions of dollars in penalties if an EIS in required.

Facts: The Operating Agreement between the DOT and the Super Ferry, dated September 7, 2005, clearly protects the State from all damages for delays caused by an EIS.

Conclusion: Public discourse is valuable. It is helpful to remove the emotions and myths from the discussion, and focus on the facts. They speak for themselves.  Mahalo for letting me share mymana`o.

Ron Sturtz is the President of Maui Tomorrow Foundation, Inc, a non—profit organization committed to protecting Maui’s future through wise land planning, responsible growth, and environmental protection.


Dear Officials,RE: 404 & 401 Permits for Expansion of Ma`alaea Harbor WQC No. 0000231/ Army Authorization No. CW 94-003The Sierra Club, with 4000 members statewide, strongly opposes the expansion of Ma`alaea as proposed in the most recent mitigation plan and discussed in the draft water quality certification. Issuance of these approvals would, among other things, (1) violate the law; (2) degrade water quality; (3) disturb threatened and endangered species; (4) destroy acres of coral reef habitat; (5) destroy surfsites; and (6) destroy a sandy beach. The mitigation plan is simply unacceptable.

The Army Corps cannot allow this project to proceed because of its significant damaging economic and environmental impacts.

The environmental impacts are mentioned below and in the various environmental documents that the Corps has prepared. Further evidence of significant adverse effects will be presented by others in their testimony.

The Department of Health is required by law to follow its own administrative rules. Every provision of Hawai`i Administrative Rules 11-54 is a water quality standard that cannot be violated. By law, DOH must do more than examine the numeric standards.

A. Violation of 11-54-01.1

Waters whose quality are higher than established water quality standards shall not be lowered in quality unless it has been affirmatively demonstrated to the director that the change is justifiable as a result of important economic or social development and will not interfere with or become injurious to any assigned uses made of, or presently in, those waters. 11-54-01.1

The proposal lowers water quality. The July 1994 FSEIS and the internal staff determination (p. 4) note water quality within the Harbor will be degraded. They also note the recreational uses of the area will be interfered with — and in fact will be wiped out: the sandy beach and at least one surfsite will be destroyed.

B. Violation of 11-54-03(c)(1)

By law, the marine waters just outside the existing harbor are Class AA. 11-54-06(a)(2)(A) and 11-54-06(b)(2)(A) specifically define as Class AA, “all waters in state or federal fish and wildlife refuges and marine sanctuaries” and “all open waters in the refuges or sanctuaries established by the U.S. Fish & Wildlife Service or the National Marine Fisheries Service.”

Huaka‘i Kaho‘olawe Day 4

By Neola Caveny

For the last time, the sound of the pū wakes us, and we scramble to pack sleeping bags and night clothes, leaving us in bathing suits and wetsuits in the pre-dawn chill. There’s a fire built on the beach, and some of us huddle around it – not so much for the physical warmth as for the sense of companionship with people with whom we have formed a bond, however temporary. Sitting on a log, I talk with Kukui, from Wai‘anae, O‘ahu, about taro lo’i restoration projects there, and how that relates to similar projects on Maui. Why haven’t we talked before? Oh well – next time.

Read moreHuaka‘i Kaho‘olawe Day 4

Huaka‘i Kaho‘olawe Day 3

By Neola Caveny

Another incredibly refreshing sleep. Either the air mattress I insisted on bringing (after all, we’re not backpacking here) or the Advil I was advised to take by our trip physician (mahalo, Dr. Karen) are working, or it might just be the mana of Kaho’olawe. I walk out to the beach alone to see the sunrise (it managed to make it on its own that day), and am greeted with a “WHHOOMPH” sound that I can’t at first place. Straining my eyes in the pre-dawn light, I see several whale spouts less than 50 feet out in Hakioawa bay. Again they give their morning greeting before traveling on around the point. Craig, a kua who is also a KIRC commissioner and sleeps on the beach every night (“not so many centipedes”), tells me that they are a pod of three who regularly hang out in the bay. By then, I am more than ready for the hike “topside”, which is our reward for all the hard work the past two days.

It’s hard to describe what the 28 of us see on our 9 hour excursion (it was supposed to be a half-day hike, but quite a few of us were slower than K, our PKO leader, anticipated—myself being the slowest, thanks to terminal blisters). Almost total desolation, on one level, but so much life, and rebirth, on another. But, above all, there are the incredible views of five of the eight main islands of the Hawaiian chain, including the snow on Mauna Kea. You get a sense of Kaho’olawe as the piko (center) of the islands. And you see the progress that has been made already, measured in a thriving ‘a’ali’i bush in bloom, or ‘ilima or pā’ū-o-Hi’iaka growing across the trail, or more than half the wili wili trees planted at one area looking like they’re going to make it. One of the lessons you learn on Kaho’olawe is to measure and appreciate small victories – but taken all together, they add up to a lot.


The highlight of the hike is the side trip to Puu Moa’ulaiki. At 1477 feet, it is the second highest point on the island, the site of the “Navigator’s Chair” and a lele (altar) used for offerings to Lono during the Makahiki season. To approach this sacred place, we remove our shoes and walk barefoot, in silence, (except for the occasional “ouch” and stifled whimper) for about 1/4 mile over lava rock (all right, maybe it was less than that, but I’m going by what my feet told me). Incredibly, Steve and Antony, the two EODs (Explosive Ordnance Disposal technicians) who met us at the top earlier with chilled water, join with us in the barefoot pilgrimage to Pu’u Moa’ulaiki. The view and experience are well worth it. This is where master navigator Nainoa Thompson came to study the stars, wind and currents for the Hōkūle’a’s journey south, and you can see, in a small way, what he must have seen looking out from this place.

Back at camp, after dinner, everyone shares their mana‘o and na’au (thoughts and feelings). Some people are uncomfortable with public speaking and are brief. Some are overcome by emotion and cannot finish. Some are eloquent, such as Dr. Karen’s metaphor of the pöhaku as people – “This one is interesting,” or “This one is heavier than it looks.” Some of the most moving testimony comes from some of the kua who stayed in Hakioawa to move more pohaku and prepare dinner while the rest of us went topside. A group of women had gone further up the streambed and, climbing up the side, found a group of healthy native wili wili trees of at least three generations, with the keiki growing at their roots, that no one had known was there. It is another sign of life, and it is celebrated.

It’s sometime around midnight when everyone finally crawls into their sleeping bags on the beach. No tents tonight—we broke camp before dinner and have everything possible packed, for a quick getaway in the morning, when the Pualele arrives around 6:30. Another night of deep sleep—this time under the stars and the just-past-full moon. The only jarring note is the light spill into the sky from South Maui, which almost blocks out the stars – from Ma’alaea to Mäkena, an almost solid line of lights reminiscent of Miami Beach. And they want to build more…

NEXT – (Day 4)


After 3 (’55, ’59 & ’79) attempts to create a safe harbor at Ma`alaea, the Army Corps of Engineers has proposed a plan for construction of a 620 ft breakwater, and blasting of a new channel. The plan is a relic of 1960’s planning and holds losses for nearly every group of harbor users, surrounding residences and businesses.

Since the Army Corps plan is based on models, there is no guarantee that their $10 million plan will actually effectively block the south swells that threaten harbor safety. Remember, this the same group that thought blasting the reefs of Kalama Park and building a sea wall was a great idea. Time has proven them wrong and the costs are being born by downshore property owners.

The list of losses connected to the Harbor Plan is a long one:

1. Reef Loss
4.8 acres of productive reef, home to over 120 marine species, will be destroyed. The Corps plans to “mitigate” by creating a 3.3 acre artificial reef. No location is given. Another 1.5 acres is expected to grow back along the newly blasted Harbor channel. No statements are made at length of time this will take, or quality of habitat that will result, especially if water quality is changed by siltation (coral reefs are very sensitive to loss of light and silt blocks light).

2. Beach Loss
The last remnant of what was once a wide sandy curve of sandy shoreline along Ma`alaea Bay (inside the current harbor area) will be paved for a parking lot. Several Ma`alaea condos enjoy this beach. Canoe paddlers use it as a landing.

3. Beach Erosion
The addition of yet another hardened structure along the bay (the proposed breakwater) is expected to continue the pattern of downshore erosion that has forced Ma`alaea condo owners to spend $50,000 on sand replenishment in 1998. Sea Grant erosion expert Rob Mullane confirms that “the existence of the harbor accelerated the coastal erosion and beach loss along the shoreline to either side. The harbor acts as a huge sediment sink, which traps large amounts of sand moving along the coast. There used to be sand along the shoreline on either side of the harbor. The seawalls that went up in response to increased rates of coastal erosion contributed to the beach loss along the coast towards Kealia, but the original and major factor was the construction of the harbor.”

4. Siltation
Near shore waters will have greater turbidity (dissolved solids) during 2 year plus construction process and very likely for a long time after. Dredging & blasting causes very fine particles- “silt,” that do not sink and settle like coarser sand, but remain suspended in nearshore waters, smothering reefs and affecting health of marine life. Water quality concerns are dismissed by the Army Corp’s Environmental Impact Statement (EIS). The EIS claims that siltation will not be a problem during construction “if best management practices are followed.” No examples are cited of similar projects that had no adverse impacts. The EIS also expects any post construction silt to be naturally carried away to deeper waters. Experts from US Fish and Wildlife Service disagreed with this analysis and called for a plan that did not destroy so much marine habitat.

5. Surf Spots
A popular surfing spot enjoyed by Maui’s youth will be destroyed, the Corps EIS claims no other breaks (including the famous “Ma`alaea Pipeline”) will be affected. Those who have grown up surfing Ma`alaea disagree. They claim maps in the EIS show the pipeline in the wrong place (conveniently further down from the harbor expansion) impact zone. They further believe that the surf at several other breaks will be modified by the proposed plan.

6. Whale Habitat
Humpback whales frequent the waters of Ma`alaea Bay from November to May. They are often observed 100 yds or closer to the reef area slated for demolition. The Corps overcame objections of state and Federal agencies claiming the plan would harm whales by stating that the proposed harbor plan will allow blasting and dredging of reefs only from June to November (but exceptions can be made by giving a 10 day notice to National Marine Fisheries Service!) Once the years of construction are complete, the threats to whales continues due to doubled harbor capacity – 130 additional slips, 51 commercial. Increased commercial activity degrades water quality through pollutants released from boat engines and puts 50 more commercial boats making multiple trips a day in a sensitive habitat area where whales seek a sheltered place to bear and nurse their young.

7. Turtles
Extremely endangered Hawksbill turtles nest and hatch young from June to September (the time proposed for reef destruction to avoid whale season) at nearby Kealia Beach (.7 mile from Ma`alaea harbor). Young hatchlings rest and feed on the Bay’s reefs before heading out to sea. Turtles find shelter in undersea caves and crevices formed by natural reefs. Concrete structures do not offer such habitat. Green sea Turtles (threatened, but not endangered) are found in abundance in the area surrounding the proposed breakwater. Their supply of limu will be killed off during the destruction of reefs. They will be forced to leave their chosen home and compete for food elsewhere if they are not directly killed or injured during reef destruction.

8. Loss of Sustenance Gathering Sites
Reef’s that will be destroyed are home to abundant fish, sealife and limu. Local people dive and spearfish and gather limu here. Years of construction activity with noisy barges, dredging, transport barges etc. will disturb local residents, surfers, fisherman and boat users as well as marine life.

9. Loss of Resources for Existing Fishing Fleet
Harbor expansion plans do not mention the very real possibility of slip fees being raised. Increased commercial competition will divide the existing pool of customers and fish into ever smaller shares. If fees are raised, only the larger, corporate vessels will be competitive. The family based Ma & Pa operations will be forced out.

10. Cultural Impacts
The Hawaiian culture values the oceans as an interconnected web of life. Kanaka Maoli understand that when “man plays god”- destroying a natural ecosytem that has taken centuries to grow (like coral reefs), he seldom understands enough about all the levels that the system functions on to rebuild it “as good as new.” Ma`alaea was a special place to Hawaiians. The village site mauka of the Harbor has the largest collections of petroglyphs on Maui (Source Elsbeth Sterling/ W.M Walker survey c. 1920’s). The Name Ma`alaea is believed to be derived from the alae – or red healing iron oxide ocher compound found both on land and in waters offshore near Kapoli spring. The present breakwater covers many alaea beds that once existed. The Harbor itself was built on a foundation of disrespect for Hawaiian culture. The very stones of this ancient village were robbed to create the breakwater, including the huge boulders that formed a prominent heiau – 60′ x 90′ with walls 6′ thick and 8′ high. It is very unlikely that any protocol was followed in this procedure. Ka Poli spring, prized in ancient times as a puna wai in a dry region, was covered by the harbor’s restrooms and turned into a cesspool. Inez Ashdown reported in her 1971 historical account,” Ke Ala Loa” that she was shocked to find the village stones carried away by the original Harbor contractor in 1952 after she had surveyed and marked 40 sites for preservation. It is believed that the Piko stone and Adze sharpening stone in front of Buzz’s Wharf restaurant are remnants of this Village. The harbor was built by a culture that had just won a war against mighty nations-now they declared war on the natural environment and made a plan to take on these mysterious forces. Having little understanding of how these forces operated, their plan failed and now we are only offered more destruction to cover their embarrassment. This was never the way of the Hawaiian culture and several kupuna spoke up at the last hearing on the matter. They stated that the Hawaiian people were not consulted about the harbor plan. The Army Corps response was to end a letter and some complicated reports to all Hawaiian organizations on Maui. Not surprisingly, most did not respond. No gatherings were called. No one asked the people who grew up on Maui’s waters and had no commercial interest in their use what they thought about such a destructive plan. The Office of Hawaiian affairs sent a response signed by a staff person that in spite of the likely impacts to marine life, reef habitat and water quality, they found no cultural impacts. It is unknown if the elected board of OHA ever deliberated on the matter. It would seem unlikely that such a plan would be approved by the majority of OHA Trustees since it needlessly destroys those things that nourish local people. This does not reflect Hawaiian cultural values of malama o ka `aina. Historically, Ma`alaea figures prominently as a landing place for Hawaiian battle fleets and commerce, although unruly weather caused the lee of McGregor Point to be more favored by many. Apollonia Day held Ma`alaea in special regard. Numerous surveys in modern times have indicated that the wide variety of marine life found in the harbor area and surrounding reefs is quite unique in its diversity. This has been reported by researchers from the late 20’s on. In spite of the many pollutants and abuses the waters here keep struggling to renew their life giving ways. We must respect what is here stand united for a plan that creates harbor safety without destroying its resources.


Department of Health’s Safe Drinking Water Branch is currently processing an underground injection permit to authorize the deepening of 2 sewage injection wells at the Ma`alaea Triangle Wastewater Treatment Facility. The permit number is # UM-1954.

DOH is also considering the permit renewal for 2 sewage disposal wells for the Milowai-Ma`alaea Condominium and 2 others for the Kanai a Nalu condo.

If you are concerned about the impacts of these projects or want more information call DOH at 586-4258.

Analysis by David Frankel, Sierra Club, Hawaii Chapter

ACTION: Write the DOH and DLNR if you agree. Official comment period on this round of decision making is closed, but letters still have impact. Copies can be sent to the addressees below.

Michael Wilson, Chairperson
Department of Land and Natural Resources
P.O. Box 621
Honolulu, HI 96809

District Engineer
U.S. Army Engineer District, Honolulu
Building 230/CEPOD-ET-PP/Lennan
Fort Shafter, HI 96858-5440
Clean Water Branch
Hawai`i State Department of Health
919 Ala Moana Boulevard, Room 301
Honolulu, HI 96814-4920